Bank’s sanctions policy and AML/CFT measures 

AML/CFT and Sanctions Policy

Statement

AML/CFT Policy

IDBank CJSC (hereinafter referred to as the “Bank”) is committed to maintaining a strong framework for preventing money laundering, terrorist financing, proliferation financing, and other forms of financial crime. The Bank seeks to ensure that its products, services, and delivery channels are not misused for unlawful purposes.

The Bank adopts a zero-tolerance approach toward knowingly establishing or maintaining business relationships with, or executing transactions for, persons involved in, or reasonably suspected of involvement in, money laundering, terrorist financing, or related predicate offences.

To this end, the Bank implements all reasonable and proportionate measures to identify, assess, mitigate, and manage AML/CFT risks, in accordance with its internal policies, the requirements of the Central Bank of the Republic of Armenia, and relevant international standards, including the FATF Recommendations.

To support this commitment, the Bank has established an Anti-Money Laundering and Countering Financial Crime Policy that defines the principles, procedures, and internal controls designed to identify, manage, and mitigate financial crime risks associated with the Bank’s activities.

The Bank applies a risk-based approach to financial crime risk management, taking into account the nature of its customers, geographic exposure, transactions, products, services, and delivery channels. This approach enables the Bank to implement controls proportionate to the level of identified risk.

As part of this framework, the Bank implements measures designed to identify and manage financial crime risks, including:

• Conducting periodic assessments of financial crime risks related to the Bank’s customers, geographic exposure, transactions, products, services, and delivery channels
• Applying risk-based customer due diligence procedures, including enhanced due diligence measures where high levels of risk are identified
• Monitoring customer transactions and behaviour to detect unusual or potentially suspicious activity
• Identifying suspicious transactions and submitting mandatory reports to the Central Bank of the Republic of Armenia in accordance with applicable legal and regulatory requirements
• Implementing measures designed to prevent the misuse of the Bank’s products and services for criminal activity
• Refusing to establish or continue business relationships where financial crime risks cannot be appropriately managed
• Maintaining records related to customer relationships and transactions in accordance with applicable legal and regulatory requirements
• Providing mandatory AML/CFT and sanctions training to all employees, with additional role-based training where appropriate

These measures are illustrative and not exhaustive. The Bank may apply additional controls or procedures as required by law, regulation, or internal policies.

In order to comply with applicable legislation, regulatory requirements, and internal policies, the Bank may decline to process transactions, refuse to establish or maintain business relationships, freeze assets where required, or take other appropriate actions where financial crime risks are identified.

The Bank’s internal policies and risk management standards may establish stricter requirements than those required by applicable legislation. Accordingly, the Bank may decide not to support certain customer relationships or transactions where the associated financial crime risks are considered unacceptable.

The Bank also recognizes the evolving nature of financial technologies and permits certain transactions involving crypto-assets, provided such activities comply with the legislation of the Republic of Armenia and applicable regulations of the Central Bank of the Republic of Armenia.

Customers may, at their own risk, carry out transactions aimed at acquiring crypto-assets for investment purposes, exchange one crypto-asset for another, or make and receive payments related to goods or services where such transactions are permitted under applicable legislation.

At the same time, the Bank does not provide services aimed at executing crypto-asset transactions to foreign companies that directly or indirectly provide crypto-asset services within the territory of the Republic of Armenia unless they have an authorized subsidiary, representative office, or branch in the Republic of Armenia and have obtained the relevant authorization from the Central Bank of the Republic of Armenia.

Anti-money laundering, terrorist financing and proliferation financing

The Bank’s AML/CFT framework is based on the Law of the Republic of Armenia on Combating Money Laundering and Terrorism Financing, the regulations of the Central Bank of the Republic of Armenia, and other applicable legal acts.

The Bank prohibits certain customer types that pose an unacceptable level of money laundering, terrorist financing, or proliferation financing risk, including, but not limited to, shell banks and customers subject to terrorism-related sanctions or prohibitions. The Bank does not open or maintain anonymous accounts or accounts under fictitious names, nor does it open accounts identified solely by numeric, alphabetic, or other symbolic expressions. In addition, the Bank does not establish relationships involving bearer securities.

The Bank rejects transactions or refuses to establish a business relationship where the customer fails to provide the information or documentation required to comply with applicable legislation and internal policies.

It is prohibited to conduct transactions or establish business relationships involving activities related to nuclear energy where such activities are not compliant with applicable legal and regulatory frameworks, as well as “red-light” or illicit adult services and marijuana-related businesses, subject to the legislation of the Republic of Armenia.

The Bank may also restrict or prohibit certain business activities where financial crime risks are considered unacceptably high.   

Furthermore, the Bank applies more stringent controls to customers and activities that may present an elevated risk of money laundering, terrorist financing, or proliferation financing, including cash-intensive activities, politically exposed persons (PEPs), correspondent banking relationships, and customers established in jurisdictions identified as having strategic AML/CFT deficiencies, among others. In such cases, the Bank applies enhanced due diligence measures, increased monitoring, and stricter approval processes in line with its risk-based approach.

Sanctions Compliance

The Bank is committed to complying with applicable international sanctions and restrictions.

As a responsible participant in the international financial system, while at the same time valuing and protecting the interests, security and continuity of its operations, the Bank complies with the sanctions and/or restrictions of the United Nations Security Council, the European Union, the United Kingdom(HMT), the United States(OFAC), and other relevant international bodies.

The Bank maintains internal controls designed to prevent transactions or business relationships that may result in violations of sanctions requirements. Where necessary to comply with legal and regulatory obligations, the Bank may reject transactions, refuse to establish or maintain a business relationship, freeze assets, or take other appropriate measures.

   Wolsfberg Group Anti-Money Laundering Questionnaire